At Peters & Co. Limited ("Peters & Co.") we appreciate the importance of information and privacy, and we respect the privacy of our customers, employees, consultants, and website visitors, just as we expect them to respect ours. An important part of our commitment to service excellence is our commitment to the privacy of personal information entrusted to us.

Privacy of your personal information is an essential element of the business we conduct. The range of products and services we offer continues to expand and the technology we use continues to change. But no matter how business or technology changes, we continually strive to protect the privacy of personal information. Policies and procedures, which we practice in order to protect this information, are in place across Peters & Co. This overall Privacy Policy also discloses the privacy practices for our website.

Our commitment to your privacy is demonstrated in Peters & Co. website information practices, including what type of information is gathered and tracked, how the information is used, and with whom the information is shared. Our Privacy Policy complies with the OECD Privacy Guidelines on the Protection of Privacy and Transborder Flow of Personal Data Guidelines, and with privacy legislation that defines "personal information" as information about an identifiable individual, but does not include the name, title, or business address or telephone number of an employee of an organization.

Protecting Privacy Means:

We do our utmost to keep your personal information in strict confidence.

You have control over your information and have access to it.

We respect privacy when we market our products and services.

Why We Need Information and How We Use It

Peters & Co. may collect personal information when an individual or organization elects to do business with us or have us conduct business services or transactions on their behalf. Peters & Co. uses that information to carry out the functions associated with those roles.

In providing any of the business or services, personal information may be shared with affiliated companies or third parties who have been retained by Peters & Co. to assist us in carrying out administrative or technological functions associated with those services.

We collect, use, and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances.

Peters & Co. may also have custody of personal information because a corporate client has elected to do business with us or have us conduct business services or transactions on their behalf. Those cases might include us processing or administering information, transactions, or payments, and record keeping associated with these activities. In those circumstances, we act as instructed by the organization retaining us and as required by law and practice.

Electronic Information

You can visit our Company Overview section on our website to learn more about our company and the services we offer or simply to gather information, and you can do that without disclosing your personal information.

If you choose to provide us with information about yourself, we will act in a responsible manner. We may store and disclose personal information as allowed or required by applicable law, including making disclosures that are necessary or advisable to (a) protect the rights, safety or property of Peters & Co. or others and (b) to conform to legal or regulatory requirements.

We sometimes collect or authorize third parties to collect anonymous information from visits to our website to help us provide better customer service. For example, tools keep track of the domains from which people visit our website, and aggregated statistical data helps measure visitor activity on our website - but we do it in ways that keep the information anonymous. We collect this information for statistical purposes and for evaluating our website to make it more useful to visitors.

Sharing Information

Information obtained when you engage our services is only disclosed to third parties with your consent.

There are some exceptions to the above rule. For example, we may collect, use and disclose information if we:

Use an outside company to process information:
At times, we may use the expertise of an outside company to do work involving some personal information - for example, operating record keeping systems or printing tax forms. When we do, we select the company carefully and confirm that it uses standards comparable to ours.

Must disclose information for legal reasons:
We may be compelled to release information by legislation, a court of law, to a regulatory authority, a successor trustee, or as part of a sale or reorganization of our business. If so, our policy is to release information only to the extent that we are required.

Have to protect the interests of Peters & Co.:
In certain circumstances, Peters & Co. may have to collect, use, or release information for our protection; for example, in collecting accounts or in the detection or prevention of fraud.

Consent

When you engage our services, we will only use personal information with your consent.

Consent can be expressed or implied. Expressed consent can be verbal or written. For example, an application to purchase certain investment vehicles may contain a written consent for our use of your information to carry out your instructions; or you might consent to release the information over the phone.

Consent is implied when we can reasonably conclude that you have given consent by an action you have taken or not taken, or when the context reasonably requires that we have and use information to carry out what you have asked us to do.

You can withdraw your consent any time after you have given it to us, provided there are no legal requirements to prevent this. If you do not consent to certain uses of information or if you withdraw your consent, we might not be able to provide a particular product or service. If so, we will explain the situation to you to help you with your decision.

We Protect Your Information from Error, Loss, and Unauthorized Access

We have implemented people, process, and technology measures intended to protect personal data that we have while it is under our control. We have no way of controlling or imposing controls on third parties, and cannot be responsible for the actions, negligence, or failures of others, whether or not that affects you or information about you. We do, however, seek to ascertain that third parties we deal with have Information Security and Privacy policies and procedures in place that are comparable to our own.

Our employees who have access to personal information are made aware that it is confidential, and must certify regularly that they maintain the confidentiality of information to which they have access.

Our computer security specialists build security into all our computer and electronic communication systems. This protects personal information while it is stored in data files and when employees are using it. Unfortunately, it is relatively easy for a third party to intercept and read information sent over the Internet or via unencrypted email.

Your Information Is Destroyed When It Is No Longer Needed

We keep your information only as long as we need it for the products and services we have been hired to deliver or to meet legal requirements. We either destroy information or render it anonymous when it is no longer required and in compliance with regulatory mandates.

Access to and Accuracy of Personal Information

You can check your information to verify, update, and correct it, and to have obsolete information removed. Copies of all new client application forms and updates are provided to you once they have been approved. Please verify the accuracy of the information on this form and notify the Privacy Officer at Peters & Co. should you note any discrepancies.

To find out if we have any personal information about you, or if you feel information about you has been misused, mishandled, or inaccurately gathered, please contact the Privacy Officer at Peters & Co. We may require proof of your identity before providing a copy of personal data that we have about you.

You may challenge the accuracy of the data that we have about you, and you may request the information be erased, changed, or completed. We may be unable to provide a copy of your personal data, and will advise you of the reasons for same, which may include, among other things, the information having been destroyed or subject to legal privilege.

We do not charge for verifying or correcting your information, but there may be a charge if you want a copy of records or if a special expense is involved in retrieving your information. We will advise you of any charges in advance.

You Can Find Out to Whom Information Is Given

If you ask, we will let you know the names of outside companies or organizations we have given your information to. This will not include information given to outside companies used to do work for us, such as tax form printers. It also will not include disclosures to Canada Customs and Revenue Agency in reports like T5s, and it will not include disclosures where we are prohibited by law from advising the individual of the disclosure.

We Respond to Requests Promptly

We will deal quickly with your request to see your information and respond within 30 days. If we need to extend the time, or we have to refuse the request, we will tell you why (subject to any legal restrictions) and we will notify you of the reasons for the extension and your rights under applicable legislation with respect to the extension.

We Correct the Information

Whenever possible, we will correct any information we may have given to any other organization. If we have received the information from another party, we will let you know the name and address of the party so that you can ask them to correct it.

We Protect Other People's Privacy When We Make Information Available to You

There may be files that include information about you and other people which is confidential to Peters & Co. or our corporate clients, or which is the property of Peters & Co. or such clients. Because we value everyone's confidentiality and legal rights, we cannot make these files available outside of Peters & Co. or our related companies. In cases where we can separate information about you from the information of others, without affecting another's confidentiality or legal rights, we will make your information available to you.

We Monitor Our Compliance With the Peters & Co. Privacy Policy

We have procedures in place to assist our employees in the practice of the policies. Our internal compliance officers monitor the adherence to these policies and report any findings to a committee of the Board of Directors of Peters & Co. We are committed to upholding the Peters & Co. Privacy Policy.

Resolving Concerns Is Important to Us

Peters & Co. is committed to providing the highest level of service. That includes treating everyone with the greatest respect and consideration. Despite our best efforts, though, some things do not happen as you or we would want them to - whether it is a misunderstanding, or someone feels they were treated unjustly. Whatever the circumstances, resolving the problem is our primary concern.

How to Contact Us

Any questions or concerns regarding our policies or procedures on personal information can be directed to our Privacy Officer by any of the following means. We may ask for further documentation or information in order to verify your identity when you make your request.